Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 780]
Action Amend regulation to require each child day center to implement policies for the possession and administration of epinephrine
Stage Fast-Track
Comment Period Ended on 12/17/2025
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11/18/25  11:25 am
Commenter: Amanda Tucker, AHYMCA ELCs

Opposing the proposed policy on Epinephrine
 

Hello,

I am the Director over two Early Learning Centers in the state of Virginia. The Centers are Non-Profit Centers. This would be a costly hit to our program by paying for Epinephrine that most likely will sit and expire and have to be purchased again, over and over to remain in compliance. This reminds me of having to purchase the activated charcoal for years and not be able to use it as it was deemed only a medial professional could administer it. So in my opinion if only a medical professional can administer activated charcoal, which is not an actual medication, then why are we even thinking of allowing Early Learning Staff who have no medical background to have the authority to give an actual medication without direct medical instructions by a medical professional?

I do not feel comfortable with my staff taking on this task as we are not medical professionals and we do not have an RN or School Nurse on staff who has had multiple years of education to know how to detect reactions and be able to know for sure the proper dosage.

As others have said in opposition, if we do have a child in our care who has a true allergy then their pediatrician has prescribed the Epi pen, we have been provided the allergy action plan, and we have MAT trained staff who can administer it in the event that it is needed, and we will always call 911 weather they have an epi pen or not. 

We need to leave the medical side of things to the medical professionals and School Nurses in the Public Schools. 

Thank you for allowing me to give my opinion on this matter and I hope that you listen to those of us who are in the field and doing this job every single day.

 

 

CommentID: 237667